Bit 2 Invest is committed to protecting your privacy and maintaining the security of any personal information that we receive from you.
What is the purpose of this policy?
The purpose of this policy is to explain to you what personal information we collect and how we and our associated companies may use it. Companies are associated with us if they are our subsidiaries or we are both subsidiaries of the same corporate entity.
We are the controller of any personal information that you provide to us, which means that we decide the purposes and means of the processing of that personal information.
How do we obtain and store your personal information?
We obtain your personal information through applications, emails, letters, telephone calls, text messages, cookies, and conversations when you register in our services and work with them (including the personal information gained when you use our learning tools, demo accounts, and trading simulators).
We may monitor or record phone calls with you and monitor (and maintain a record of) all emails and electronic communications we send or receive.
We follow strict security procedures in the storage and disclosure of the personal information that you have given to us to prevent unauthorized access.
What types of personal information do we collect and process?
How do we use your personal information?
As well as checking your identity, the personal information we hold may be used for:
When may we share your personal information?
Generally, we require that organisations outside our associated companies with whom we share your personal information acknowledge the confidentiality of your data, undertake to respect your right to privacy, and comply with the data protection principles and this policy.
How may we share your personal information?
The info we may collect is anonymous and will help us improve your user experience with our mobile application even better!
We may gather info and use a third-party service to understand how you interact with our app, view bugs and crashes, provide customer support, and even enhance or improve your accessibility within the app.
This information is a great benefit to you.
The third-party service we use is Smartlook.com.
To provide those benefits, we sometimes may need to collect and transfer anonymised data, such as the features used in the app, what users are tapping or swiping on, which screenshots are being captured, and identify the virtual device.
Rest assured that none of the anonymous data we may collect involves personal or financial information, other sensitive data, or user-generated private content. Also, any data we may transmit will not include your device’s camera, microphone, or other user inputs. All transmitted data are protected by SSL encryption.
What is the legal basis for our processing of personal information?
The legal basis for our processing of personal information will depend on why we process your personal information.
Where you wish to enter into or have signed a contract to receive services from us, we will process your personal information to enable us to enter into and perform our contract with you. If you do not provide the personal information requested, we may not be able to provide some or all of those services to you.
We may also need to process your personal information to comply with our legal and regulatory obligations including in relation to performing anti-money laundering, terrorism prevention, and sanctions screening checks, complaints, and investigations or litigation.
We also have a legitimate interest to process your personal information for:
In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
What is the place of processing?
The data is processed at our operating offices and in any other places where the parties involved in the processing are located.
Depending on your location, data transfers may involve transferring your personal information to a country other than yours. To find out more about the place of processing of such transferred personal information, you can check the ‘Using Your Personal Information’ section.
Please note that we use third-party providers to store personal data; therefore, we may transfer your personal data to a provider's data storage facility in a different country.
How long will we keep it?
We hold personal information about you on electronic and/or paper files whilst you are a customer and for at least three years after you cease to be a customer. Please note that pursuant to the applicable anti-money laundering and terrorist financing legislation some of your personal information must be retained for a term of seven years. Such personal information includes:
In addition, the above data shall be stored for our defence of legal claims during the limitation periods envisaged by the applicable legislation.
Please be informed that the above personal information will be encrypted and securely stored in our IT system, will not be used for any purposes other than for the purposes indicated above and will be erased from our system at the expiration of the seven-year period. Please be assured that access to the above personal information will be restricted during the whole period of storage.
What is a Cookie and why do we use it?
Cookies are small pieces of information that are stored on your computer by a website you visit in order to enable you to perform certain functions on the website and regulate its content to your preference. They can store data on the pages for which you have provided key information (for example, when you provide a password), but only once you are asked and you accept the storage of this information. Cookies may be used on some pages of the site for us to provide you with a more customised web browsing experience. They are not used to determine the personal identity of anyone merely visiting the site.
Types of cookies we use:
As already mentioned, we use cookies to ensure the optimal functionality of our website and cater our content to your personal preferences. If you have further questions, please do not hesitate to contact your SC-FC broker.
If you are unhappy about any aspect of the way we collect, share, or use your personal information, we would like you to tell us. You can contact us via your broker.
What are your privacy rights?
This section explains your rights in relation to your personal information in more detail.
ACCESSING YOUR PERSONAL INFORMATION
When can you request access?
You have the right to:
You can request copies of the paper and electric records about you that we hold, share, or use. To deal with your request, we can request proof of identity and enough personal information to enable us to locate the personal information you request.
When will access not be provided?
We can only provide you with your personal information, not personal information about another person. Also, where access would adversely affect another person’s rights, we are not required to provide this. Due to legal privilege, we may not be able to show you anything that we learned in connection with a claim or legal proceeding.
Please clearly set out in your access request the personal information that you are requesting. If this is not clear, we may come back to you to ask for further personal information by way of clarification.
CORRECTING YOUR PERSONAL INFORMATION
How can you correct your personal information?
You have the right to obtain from us without undue delay the rectification of inaccurate personal information concerning you. If you tell us that the personal information we hold on you is incorrect, we will review it and if we agree with you, we will correct our records. If we do not agree with you, we will let you know. If you wish, you can tell us in writing that you believe our records still to be incorrect and we will include your statement when we give your personal information to anyone outside of our company.
You may also have the right to have incomplete personal information completed, including by means of providing a supplementary statement. Whether or not this is appropriate in any particular case depends on the purposes for which your personal information is being processed.
We need to notify any third parties with whom we have shared your personal information that you have made a rectification request. We will take reasonable steps to do this, but if it is not possible or may involve disproportionate effort we may not be able to do this or ensure they rectify the personal information they hold.
What are the limitations on access to and correcting your personal information?
Generally, we will let you see the personal information that we hold about you, or take steps to correct any inaccurate personal information, if you ask us in writing.
Due to legal privilege, we may not be able to show you anything that we learned in connection with a claim or legal proceeding.
ERASING YOUR PERSONAL INFORMATION
When can you request erasure?
You have a right to have your personal information erased, and to prevent processing, where:
When can we refuse erasure requests?
The right to erasure does not apply where we are required to retain it for legal or regulatory purposes or where your personal information is processed for certain specified reasons, including for the exercise or defence of legal claims.
More importantly, if we have to erase your data, we may not be able to provide you with part or all of our services.
Do we have to tell other recipients of your personal information about your erasure request?
Where we have provided the personal information you want to be erased to third parties, we need to inform them about your erasure request, so they can erase the personal information in question. We will take reasonable steps to do this, but this may not always be possible or may involve a disproportionate effort.
It may also be that the recipient is not required or able to erase your personal information because one of the exemptions above applies.
RESTRICTING PROCESSING OF YOUR PERSONAL INFORMATION
When is restriction available?
You have the right to restrict the processing of your personal information:
Do we have to tell other recipients of your personal information about the restriction?
Where we have disclosed your relevant personal information to third parties, we need to inform them about the restriction on the processing of your personal information, so that they do not continue to process this.
We will take reasonable steps to do this, but this may not always be possible or may involve a disproportionate effort.
We will also let you know if we decide to lift a restriction on processing.
TAKING YOUR PERSONAL INFORMATION WITH YOU
When does the right to data portability apply?
The right to data portability only applies:
When can we refuse requests for data portability?
We can refuse your data portability request if the processing does not satisfy the above criteria. Also, if the personal information concerns more than one individual, we may not be able to transfer this to you if doing so would prejudice that person’s rights.
OBJECTING TO PROCESSING
You can object to processing in the following circumstances:
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal information concerning you which is based on legitimate interests.
If we can show compelling legitimate grounds for processing your personal information that override your interests, rights, and freedoms, or we need your personal information to establish, exercise, or defend legal claims, we can continue to process it. Otherwise, we must stop using the relevant personal information.
If you receive newsletters or other email messages from us, you can opt out at any time free of charge by contacting us via your broker.
LEGAL INFORMATION
This privacy statement has been prepared based on provisions of multiple legislations, including Regulation (EU) 2016/679 (General Data Protection Regulation).
KEY DEFINITIONS
Personal information (or Data)
Any information that directly, indirectly, or in connection with other information—including a personal identification number—allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through our application and/or our website (or third-party services employed by us), which can include: the IP addresses or domain names of your computer, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, and other), the country of origin, the features of the browser and the operating system utilised by you, the various time details per visit (for example, the time spent on each page within the Application and/or our website), and the details about the path followed within the Application and/or our website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or your IT environment.